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Minister of National Revenue, 91 DTC 653, [1991] 1 CTC 2413 (TCC)-- summary under Paragraph 20(1)(bb) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(bb) In finding subscription fees for various investment publications to be non-deductible, Dussault TCJ. stated (p. 655): "General subscription fees for an investment publication listing and analyzing hundreds and thousands of corporations and securities is not, in my view paying 'an amount to a person for advice as to the advisability of purchasing or selling a specific share or security of the taxpayer '. ...

Canada, 99 DTC 5669, [1999] 3 S.C.R. 622, [1999] 4 CTC 313-- summary under Section 67 Summary Under Tax Topics- Income Tax Act- Section 67 s. 67 does not apply where provisions, having their own internal limiting clauses, apply In refusing to apply s. 67 to interest that was found to be reasonable in amount for purposes of the reasonableness limitation expressed in s. 20(1)(c), McLachlin J. stated (at p. 5678): "... it seems to me that Parliament intended s. 67 to apply primarily to those deductions claimed under the provisions of the Act that do not have their own internal limiting clauses.... ...

General Provisions general reasonableness provision should not be applied to interest which has its specific s. 20(1)(c) reasonableness limitation In refusing to apply s. 67 to interest that was found to be reasonable in amount for purposes of the reasonableness limitation expressed in s. 20(1)(c), McLachlin J. stated (at para. 51): "... it seems to me that Parliament intended s. 67 to apply primarily to those deductions claimed under the provisions of the Act that do not have their own internal limiting clauses.... ...

., 69 DTC 5194, [1969] CTC 265 (Ex Ct)-- summary under A Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(21)- Undepreciated Capital Cost- A taxpayer had not acquired all the incidents of title Before finding that the taxpayer had not "acquired" a drilling rig in its 1963 taxation year for purposes of the definition of "undepreciated capital cost" in s. 20(5)(e) of the pre-1972 Act, because under the Sale of Goods Act (Alberta), property in the drilling rig had not passed to the taxpayer until 1964, Cattanach J. stated (at p. 5198): "... ...

The Queen, 94 DTC 1947, [1994] 2 CTC 2021 (TCC)-- summary under Start-Up and Liquidation Costs Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Start-Up and Liquidation Costs In finding that the expenses of various categories of work done on a vessel before the vessel sank and before the taxpayer acquired title to it, were deductible except to the extent that they were capital expenditures, Bowman T.C.J. stated (p. 1949): "... ...

In reversing this finding, Robertson J.A. stated: "... there is no 'personal element' involved in the series of transactions under review. ...

Before affirming a finding of the Tax Court Judge that the taxpayer, in substance, had thereby been deducting a reserve under s. 20(1)(m), McDonald J.A. stated (para. 20): "... ...

Rinfret C.J. stated (p. 1015): "... on the proper construction of section 3(1)(b) an annuity or annual payment, received under the provisions of a contract, such as the present one, in order to be taxable must be an annual profit or gain. ...

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In finding that £90,000 paid by the taxpayer in order to secure the release of a restrictive covenant was a permissible deduction in computing the value of the consideration received by the taxpayer for the granting of the option, Carnwath J. stated (at p. 233): "... ...